Update On NY Legislative And Regulatory Developments Regarding Unclaimed Life Insurance Benefits

As reported in our November 2012 Client Alert entitled Latest Regulatory Developments Concerning Unclaimed Life Insurance Benefits, a few states have passed new laws governing claims investigation practices to address the issue of unclaimed life insurance benefits. New York's law, enacted on December 17, 2012, is scheduled to take effect 180 days thereafter. Prior to the law's enactment, the New York Department of Financial Services (Department) issued New York Insurance Regulation 200 on an emergency basis outlining standards for investigating unclaimed life insurance benefits and policy identification. While much of the new statute addresses issues that are included in Regulation 200, the law does vary somewhat from the regulation. Consequently, the Department is working on revisions to Regulation 200 to align the regulation with the new law. The idea is to have the new regulation become effective at the same time that the new statute does.